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ARTICLE · 21 MAY 2025

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Considering Using Blockchain With Personal Data? The EDPB Has Provided Guidance, Open For Public Consultation Until 9 June 2025

McCann FitzGerald LLP
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On 14 April 2025, the EDPB published guidelines for public consultation on the processing of personal data through blockchain technologies...

IrelandTechnology
Doug McMahon
Doug McMahon
Lisa Leonard
Lisa Leonard

On 14 April 2025, the EDPB published guidelines for public consultation on the processing of personal data through blockchain technologies (the "Guidelines")1. The Guidelines highlight the challenges and risks that arise in this space and note that such risks need to be carefully assessed. The Guidelines provide practical advice on matters relating to GDPR compliance, emphasising the importance of data protection by design and default and the need to carry out a DPIA prior to processing using blockchain technology.

What are the main data protection risks that arise with blockchain?

The Guidelines provide a detailed technical consideration of the various elements and properties of blockchain technology. The Guidelines note that, while blockchain comes with some potential benefits, its properties also give rise to unique data protection non-compliance risks where personal data is involved. For example:

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